Dodd Frank Act amended sec. 308 of the FIRREA to require NCUA, Office of the Comptroller of Currency, and the Federal Reserve Board to establish a program to comply with its goals to preserve and encourage Minority Depository Institutions (MDIs). The NCUA Board issued Interpretive Ruling and Policy Statement (IRPS) 13-1 establishing a MDI preservation program to comply with FIRREA § 308 goals. The IRPS identifies the procedure for a federally insured credit union to determine and document its ability to designate itself as a MDI, resulting in the ability to participate in the Program.
A reduction of 42 hours is attributed to the following program changes: (1) At the time of the publication of IRPS 13-1, the asset threshold used to define the term âsmall entityâ was less than $50 million. NCUA published IRPS 15-1 which increased the asset threshold from $50 million to $100 million. Accordingly, the number of credit unions required to retain records of their minority composition would theoretically increase because more credit unions would fall under the small entity threshold; but, with the decline in the number of credit unions since the previous submission, a reduction in the number respondents is being reported. (2) The burden hours associated with appeals due to the denial of MDI certification, have been removed from this ICR. Procedures that govern appeals to the Board have been codified as subpart B to part 746 and associated burden is being consolidated under OMB control number 3133-0198.
Adjustments has been made to remove the reporting burden of MDI status via the CU Online portal. This is duplicative to information provided on the Call Report and has been removed from this collection.
A total of 30 burden hours is requested.
On behalf of this Federal agency, I certify that the collection of information encompassed by this request complies with 5 CFR 1320.9 and the related provisions of 5 CFR 1320.8(b)(3).
The following is a summary of the topics, regarding the proposed collection of information, that the certification covers:
(i) Why the information is being collected;
(ii) Use of information;
(iii) Burden estimate;
(iv) Nature of response (voluntary, required for a benefit, or mandatory);
(v) Nature and extent of confidentiality; and
(vi) Need to display currently valid OMB control number;
If you are unable to certify compliance with any of these provisions, identify the item by leaving the box unchecked and explain the reason in the Supporting Statement.